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#690299 - 02/21/07 03:44 PM CTR Exemption
CrashDavis Offline
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Joined: Jun 2005
Posts: 283
Can a business that is a MSB but doesn't issue money orders or is a money transmitter be granted exemption status. We have a grocery store account in a small town that cashes checks but doesn't issue money orders or is a money transmitter.

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#690333 - 02/21/07 04:09 PM Re: CTR Exemption CrashDavis
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,763
Central City, NE
Sure. MSB's can be exempt; however, there is a higher level of due diligence. I believe FinCEN issued a guidance memo about this topic.

Many here at BOL would suggest that you never grant ANY Phase II exemptions - let alone to a MSB. I simply saying it is technically legal - not necessarily prudent.
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David Dickinson
http://www.bankerscompliance.com

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